Lately, when looking at pharmaceutical ethics, many organizations focus on quantity and not quality of orders. Attempting to fill as many as possible in the spirit of competition; which leads to companies mismanaging orders and wrong orders being filled. An article in the latest Pharmaceutical Technology magazine provoked the question: Whose responsibility is it to regulate the quality and legitimacy of drug orders?
This question has 15 different responses: is it the DEA, pharmaceutical manufacturing manager, supply chain laborers, or the end customer? The unknown is troubling to the pharmaceutical industry. There is no role of agreement when it comes to regualtions. So, how will the DEA’s code of federal regulations be followed by drug manufacturers? When companies encounter an issue with an order, they mainly work to solve the individual citation, but fail to look at the what’s potentially causing it. Allowing the chance for it to happen again. The most effective solution for quality assurance and compliance strategies begins with robust internal procedures. And that could be as simple as dedicating part of the manufacturing and distributing process to monitoring activity of their customers.
“People complain that quality costs money, but if they really want to see how expensive things can be, they should try a consent decree.” – Chris Moreton, FinnBrit Consulting
With the opioid epidemic growing exponentially, the DEA instituted a federal regulation that all manufacturers and distributors must check their client has the agency’s authorization to possess controlled substances. This mandate opens a need for supply chain monitoring personnel, as a result, requires minor adjustments throughout supply chain procedures. Processes and procedures are not carved into stone, and need to be continually adapted to industrial needs and requirements. A combination of strong personnel training, keeping tools and equipment updated, having a strong quality unit, and developing a quality company culture at all levels allow for a smooth adoption of change. Similarly, there should be on-the-job training and oversight on a continual basis to reduce companies’ risk.
Consequently, one of the biggest difficulties in maintaining good manufacturing practices is complacency. “Once a process or procedure is established and functional, there does not seem to be the impetus to update and revise it,” says Susan Schniepp, executive vice president of Post-Approval Pharmaceuticals. General practices that have been in place at a company for a good length of time are hard to revise. One option companies use to update their GMPs is establishing a policy that ties failure to follow procedures with an internal audit and detect improper performance. A better option to explore is upgrading company tools and equipment, especially computer-driven programs, to monitor manufacturing practices. New technologies and new product types may necessitate an update to procedures.
Where The Responsibility Lies:
The DEA planted regulations on all prescription drug manufacturers and distributors. It doesn’t verify incoming orders, rather the agency investigates orders that come across as suspicious. It has tasked the manufacturers and distributors with complying with the regulations, or face several large fines for supplying illegitimate customers. Repeat mistakes, often caused by tunnel vision, stem from a lack of monitoring orders and from “know your customer” protocols. Today, a pharmaceutical supply chain has to be in constant communication with every department. Applying vertical and horizontal communication principles passes information from the DEA, to company administrators, on down through the company. Through fostering communication between employees on several levels helps ensure the supply chain is a smooth operation.
Developing and Maintaining New Procedures:
Change is inevitable, especially when the industry is facing unheard of fines on the horizon of an epidemic. One way to incorporate new policies and procedures is to involve all parties in the process of developing them. What new protocols need followed when fulfilling orders? One way to combat an overwhelming change is to seek the help of professionals because the concept of suspicious order monitoring is new for companies and the fine print in the regulations can be intimidating. The first step is having a solid understanding of where your current order-manufacturing process is at. Having the knowledge of your employees’ abilities is crucial before incorporating new software because it informs management of the best way to introduce and train staff on suspicious order monitoring software.
At e-SupplyLink, we are those professionals your company requires. We work with DEA agents to ensure our suspicious order monitoring software complies with the federal regulations for controlled substances. Which means less work for your company. SOMLink has been on the market for eight years and continues to be a leader in suspicious order monitoring. To keep procedural alterations to a minimum, we integrate our software into existing EDI translators and ERP management systems.